A Step-by-Step Guide to the Pre-Startup Safety Review (PSSR) Process
In our previous blog post, we discussed the importance of the Pre-Startup Safety Review (PSSR) and why it’s necessary for a safe startup. In this second part of our series, we’ll guide you through the detailed steps involved in the PSSR process. From selecting the review team to preparing the final report, we’ll walk you through each stage for a thorough, well-executed review.
Here’s what you’ll find in this article:
A Detailed Look at the Pre-Startup Safety Review (PSSR) Process
The Pre-Startup Safety Review (PSSR) involves a series of detailed steps, each designed to verify safety, equipment, and procedures are in place before starting operations. Let’s take a closer look at each step:
1. Identify Pre-Startup Safety Review (PSSR)Team Members
A multidisciplinary team should conduct the Pre-Startup Safety Review (PSSR) to confirm diverse expertise is involved in evaluating the various aspects of the project. Key team members include:
- Supervisor/Technical Expert: At least one supervisor or technical person with in-depth knowledge of the process, equipment, or facility being reviewed. This person ensures the review focuses on the technical and operational integrity of the system.
- Operator: An hourly employee or operator with direct knowledge of the process/equipment to ensure that the perspective of the personnel interacting with the system daily is considered.
- Other Representatives:
- Production and Maintenance Representatives: These individuals confirm that the operational and maintenance requirements are feasible and safe.
- Safety Representative: Makes sure that safety risks are adequately addressed in the review.
- Environmental Representative: This ensures that all environmental regulations are met and that potential environmental hazards are identified.
- Production and Maintenance Representatives: These individuals confirm that the operational and maintenance requirements are feasible and safe.
For larger projects, you may also need representatives from additional departments:
- Instrument Technicians: To assess the instrumentation and control systems.
- Electrical Department: To evaluate electrical systems and safety concerns.
- Quality Control (QC): To verify that all materials, processes, and products meet quality standards.
- Other Specialists: Depending on the nature of the project, additional specialists may be required, such as those with expertise in industrial hygiene, firefighting systems, or regulatory compliance.
This interdisciplinary approach ensures that every aspect of the new operation is reviewed thoroughly from design, safety, operational, maintenance, and environmental perspectives.
2. Compile Project Information
Before the Pre-Startup Safety Review (PSSR) meeting, it is important to gather detailed information about the project so the review team comprehends the entire scope of the system being evaluated. Important aspects include:
- Process Descriptions and Flowcharts: Provide a clear understanding of the process flow, the sequence of operations, and the materials involved.
- Chemical Data: Details about the chemicals used, produced, and disposed of. This includes information about waste, emissions, and the overall material balance.
- Piping and Instrumentation Diagrams (P&IDs): Even if they are not fully developed, preliminary P&IDs or process flow diagrams should be available to help the team visualize the layout and flow of materials.
- Operating Instructions and SOPs: Clear operating procedures and emergency and contingency plans should be provided to ensure that all team members understand how the system is designed to operate under normal and emergency conditions.
- Training Materials: Training outlines and manuals for operators and other personnel must be reviewed to confirm that the team is adequately trained for the startup and operation of the new system.
- PHAs and Risk Assessments: Summary of previous Process Hazard Analysis (PHA) recommendations, Failure Mode and Effects Analysis (FMEA), and any identified risks should be considered and addressed.
- Regulatory and Permit Reviews: Ensuring compliance with environmental regulations and verifying that all required permits have been obtained or are in progress.
- Staffing and Training Requirements: Identifying the required staffing levels for safe operation and confirming adequate training.
- Perceived Risks: Document any perceived risks or concerns from the project team or PSSR team members related to safety, operability, or maintenance.
The purpose of compiling this information is to ensure that all participants in the PSSR are informed about the system’s design, risks, and operational needs.
3. Schedule the Pre-Startup Safety Review (PSSR)
When the Pre-Startup Safety Review (PSSR) is scheduled, the following activities are undertaken to conduct a detailed review, identifying any issues early enough to be resolved before startup.
- Pre-Meeting Information Distribution: Send the compiled project information to all PSSR team members at least one week before the scheduled meeting. This allows everyone adequate time to review the documents and arrive prepared.
- On-Site Meetings: The review should be conducted on-site, close to the actual installation. The team can assess the system in its physical context and make the identification of any discrepancies easier.
- Timeliness: Allocate enough time for the PSSR, which may vary depending on the project’s size and complexity. The Pre-Startup Safety Review (PSSR) may be conducted in phases for large projects, with reviews occurring as each major unit operation is completed.
- Progressive Review for Large Projects: Conducting phased reviews as each equipment or system is completed allows for early issue identification and correction, preventing startup delays.
4. Project Overview
The Project Manager (or designee) should provide a detailed presentation of the project to the Pre-Startup Safety Review (PSSR) team, which includes:
- Project Purpose and Scope: Explaining the objectives of the project, including how the process should operate, the materials involved, and the design standards used.
- Process Flow and Materials: Overview of the process flow and any key materials involved in the operation.
- Hazards: Identification of physical and chemical hazards introduced by the project. This should include potential health risks, construction materials, and chemical incompatibilities or reactions.
- PHA Summary: All PHA recommendations must be reviewed, and field-checked to ensure they are in place.
- Safety Equipment and Procedures: A review of safety-critical equipment, such as safety relief systems, fire protection, and safety procedures.
- Environmental Impact: Discussion of any environmental considerations, including potential impacts, permitting issues, and regulatory compliance.
- Industrial Hygiene and PPE: Potential concerns about worker exposure to chemicals or other hazards and the adequacy of PPE and medical monitoring programs.
- Outstanding Action Items: A review of any outstanding action items from previous reviews, such as changes in equipment or safety procedures.
This overview ensures that everyone on the Pre-Startup Safety Review (PSSR) team is aligned on the project’s objectives, potential hazards, and critical safety and operational requirements.
5. Document Review
During the Pre-Startup Safety Review (PSSR), a review of all relevant documents takes place. These documents include:
- Operating Procedures: Verify the standard operating procedures (SOPs) are clear, thorough, and address all expected operating conditions.
- Emergency and Maintenance Procedures: Review emergency shutdown and maintenance protocols confirm to the hazards, and that, ensuring they are detailed and actionable.
- Change Management: Review any recent changes to the project and associated systems. The change management checklist should be reviewed to verify that no critical modifications have been overlooked.
- Training Material: Establish that training programs cover all aspects of operation, including emergency procedures.
6. Field Verification
After the document review, the team moves to field verification, which is to be done in the field. It involves physically inspecting the equipment and systems. Constructive actions include:
- Checklists: Use checklists to guide the review and ensure all areas are covered. These checklists should be thorough and may be tailored to specific equipment types or process areas.
- Divide and Conquer: For large projects, Divide the team into sub-groups based on equipment types or other logical categories. Each group uses checklists to guide their inspection and evaluation of the equipment.
- Specification Verification: Verify that the installation matches the design specifications. This includes checking the actual equipment, materials used, and layout against the project design.
- Interface and Safety Concerns: Assess how new equipment interfaces with existing systems, identifying potential safety concerns, such as hazards arising from new equipment located near existing operations.
- Documenting Findings: Any concerns identified during the field inspection should be documented in writing or with photos. These will be used for the debriefing and to develop action items.
7. Development and Prioritization of Findings
Following the field verification, the Pre-Startup Safety Review (PSSR) team develops a list of findings and ranks them based on risk:
- Categorization: Findings should be categorized into two main groups:
- Critical issues that must be addressed before startup (e.g., safety hazards or regulatory non-compliance).
- Non-critical issues that can be resolved later (e.g., cosmetic fixes or less urgent operational adjustments).
- Critical issues that must be addressed before startup (e.g., safety hazards or regulatory non-compliance).
- Risk Assessment: Based on a risk assessment, each issue should be evaluated in terms of its potential impact and likelihood of occurrence. This will guide decisions about which issues are acceptable to resolve after startup.
- Management of Change: Identified issues that are not resolved prior to startup should be tracked under a management of change (MOC) process to ensure that actions are not lost and the project stays on schedule.
8. Debrief and Closing Conference
The debriefing meeting is where the PSSR team presents their findings and proposed actions to the project team and management, including the operators who will be responsible for the new equipment. Key points include:
- Presentation of Findings: The Pre-Startup Safety Review (PSSR) team presents their prioritized findings and recommendations, ensuring alignment with the project team and production management.
- SMART Actions: Develop SMART actions (Specific, Measurable, Attainable, Realistic, and Timely) to resolve each issue.
- Action Resolution: Agree on the priority and timeline for addressing each action, for large projects making sure the most critical issues are resolved before startup.
- Wrap-Up: Schedule and distribute the final report within the companies acceptable time frame. Discuss whether further reviews are necessary.
9. Prepare the Report
The final Pre-Startup Safety Review (PSSR) report should be detailed and include the following:
- Dates of the Review: Include all dates for review meetings and field inspections.
- Team Members: List of team members and their roles.
- Project Overview: Brief description of the process or equipment reviewed.
- Recommendations: A detailed list of recommendations, with assigned responsibilities and deadlines for completion.
For small projects, the Pre-Startup Safety Review (PSSR) report should be sent to plant management. For larger projects, it should be distributed to plant management, sector presidents, and corporate EH&S. The plant management team should also maintain a tracking system to monitor the status of action items, ensuring that key issues are addressed before startup.
The Pre-Startup Safety Review (PSSR) is the last PHA used to ensure that all safety, environmental, and monetary reviews (PA) have be addressed and are in-place for startup. I is a step-by-step approach that ensures safety, compliance, and operational readiness before a new or modified facility begins operations. It is the last safety review before commissioning. By thoroughly reviewing project details, conducting on-site inspections, and addressing issues, the PSSR process helps reduce risks and ensures safe operation. For more information on the importance of PSSR, refer to our first blog post The Importance of Pre-Startup Safety Review (PSSR).
